IRS' Economic Substance Doctrine Has Limits, 5th Circ. Told

By Kat Lucero · September 21, 2026, 5:17 PM EDT

The IRS should not invoke the economic substance doctrine whenever it dislikes a transaction's tax consequences, an advocacy group told the Fifth Circuit on Monday in an eye doctor and his...

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Case Information

Case Title

Patel v. CIR

Case Number

26-60180

Court

Appellate - 5th Circuit

Nature of Suit

Tax Court 

Date Filed

March 25, 2026